Responses to Section C. Compliance Issues

C. Compliance Issues

Question 6

Part 6.1: What resources and services are available to public accommodations and public entities to make their Web sites accessible?

Many free and commercial tools and resources are available for evaluating web sites for accessibility. A wide range of courses and tutorials address accessible web design. As web accessibility becomes a part of mainstream web development it will be integrated into all web development instruction and this is one reason to include web accessibility as part of ADA.

The more market demand there is for web accessibility training, authoring, and evaluation tools and resources, the more will become available. The increase in accessibility of a wider range of web resources will prompt more users with disabilities to use the web. This will in turn increase their knowledge of the issues, helping them to become better advocates for web accessibility. The following is a list of some of the resources used by the CIC institutions to support web accessibility initiatives:

Selected Accessible Web Design Resources:

• 1. W3C Web Accessibility Initiative, http://www.w3.org/WAI/

  2. WebAIM, http://www.webaim.org

  3. Web Best Practices Working Group, http://collaborate.athenpro.org/group/web/

  4. iCITA HTML Best Practices, http://html.cita.illinois.edu

  5. OpenAjax Alliance. http://www.openajax.org/member/wiki/Accessibility

CIC Institutional Support Websites for Web Accessibility

• 1. Illinois at Urbana/Champaign, IT Accessibility Initiative, http://itaccessibility.illinois.edu/

  2. Illinois at Chicago, http://www.uic.edu/home/wdw/accessweb/what.html

  3. Indiana, http://www.indiana.edu/~iuadapts/services/web-accessibility/

  4. Iowa, http://cs.its.uiowa.edu/wts/access.shtml

  5. Michigan, http://www.umich.edu/webaccess/

  6. Michigan State University, http://webaccess.msu.edu/

  7. Northwestern, http://www.northwestern.edu/univ-relations/webcomm/styleguide/accessibility.html

  8. Penn State University, http://www.equity.psu.edu/accesspsu/webresources.htm

  9. Purdue, http://www.purdue.edu/webaccessibility/

  10. The Ohio State University, Web Accessibility Center, http://wac.osu.edu/

  11. Wisconsin, DO-IT, http://www.doit.wisc.edu/accessibility/

Open Source and Free Tools used by CIC Institutions for Web Accessibility

• 1. AChecker, http://achecker.ca/checker/

  2. Fangs Screen Reader Emulator for Firefox , https://addons.mozilla.org/en-US/firefox/addon/402/

  3. WAVE, http://wave.webaim.org

  4. WAVE Toolbar for Firefox, http://wave.webaim.org/toolbar

  5. IE Accessibility Toolbar, http://www.visionaustralia.org.au/ais/toolbar/

  6. FireEyes add-on for Firefox, http://www.deque.com/products/worldspace-fireeyes

  7. Juicy Studio Luminosity Colour Contrast Ratio Analyzer, http://juicystudio.com/services/luminositycontrastratio.php

  8. Functional Accessibility Evaluator, http://fae.cita.illinois.edu

  9. Accessibility Evaluator for Firefox, https://addons.mozilla.org/en-US/firefox/addon/5809/

Part 6.2: What is the ability of covered entities to make their Web sites accessible with in-house staff?

Many web developers within CIC institutions are already including accessible design practices in their web development processes and purchasing decisions. Designing accessible web resources requires forethought and some planning, but it does not require special degrees or a decade of experience in web development or understanding disabilities. Developers do however, need to understand coding HTML pages according to web standards, which leads naturally to satisfying many Section 508 and WCAG 2.0 web accessibility requirements. Adhering to web standards has the added benefit of saving developers time in creating new web resources and maintaining existing pages.

If outsourcing development, the requirement for accessibility needs to be made up front in the contract with coding details on how accessibility should be addressed. Even relatively small organizations likely can find in-house expertise sufficient to produce accessible pages. Online conferencing tools can enable organizations to provide accessibility training at a relatively low cost.

The biggest challenge within CIC institutions is the decentralized nature of web development across campus units. Typically, colleges, departments, support units, research efforts, and outreach projects all have their own web development staff and their own web technologies. Students are often used in web development projects, and are by nature transient. This makes it a constant challenge to raise awareness of the importance of accessible design and provide developers with training and feedback.

Part 6.3: What technical assistance should the Department make available to public entities and public accommodations to assist them with complying with this rule?

The most important service that the DOJ can provide is to help bring web developers, accessibility experts, and people with disabilities together to share their experiences and to exchange ideas on accessible design. People with disabilities will benefit from more accessible web resources and developers will be certain that their efforts are actually meeting the functional needs of people with disabilities. Results of these exchanges can be used to develop and share best practices for accessible web design. The Disability Technical Assistance Project (DBTAC) and State Assistive Technology Projects are potential models that could provide regional centers of support and coordination for ADA implementation of web accessibility. Hosting regional centers at universities and colleges would support the integration of web accessibility into college curricula that would help build accessible web design knowledge and practices into the next generation of IT professionals.

The diversity of web development and deployment technologies, along with developers of widely varying skills, and understanding of the needs of people with disabilities will require a decentralized approach to providing resources. One problem web developers often face is trying to translate general web accessibility to the specific technologies they use and the features of the web sites and applications they are creating. Because of this, implementation guides need to be tailored to meet developer needs.

The DOJ could also support the development of free and open source tools to support accessible web evaluation, authoring, and development environments, systems, and frameworks. This will help organizations easily begin the process of learning about their web sites' accessibility issues. The more that development and evaluation tools can help web developers learn about and apply web accessibility best practices, the more accessible their web sites will be. One example project is the Accessibility Task Force of the OpenAjax Alliance (http://www.openajax.org/member/wiki/Accessibility).

Question 7. Are there distinct or specialized features used on Web sites that render compliance with accessibility requirements difficult or impossible?

Every effort should be made to use technologies that render/create web sites that are accessible, including keeping current with web coding practices and adaptive technology. If this is not possible in certain cases, the ADA prescribes providing alternative options for access to the information, goods,and services. (See Accessibility of State and Local Government Web sites to People with Disabilities, available at http://www.ada.gov/websites2.htm.) These alternatives must provide an equal degree of access in terms of hours of operation, and range of available information, options, and services.

It must be verified that these alternative provide acceptable, equivalent functional performance and information access. Generating accurate synchronized captions, audio descriptions, etc. for video content or transcripts for podcasts requires considerable resources. For sites presenting large volumes of content through video or audio, transcripts/audio descriptions, this can be prohibitive if required for every instance. The same applies for production of alternative media such as tactile representations of complex charts and diagrams, Braille encoding of music scores, math, or chemical equations where simple alternate text does not suffice. In these cases, provision to meet such requirements on an as-requested basis should be made.

Question 8. Given that most Web sites today provide significant amounts of services and information in a dynamic, evolving setting that would be difficult, if not impossible, to replicate through alternative, accessible means, to what extent can accessible alternatives still be provided? Might viable accessible alternatives still exist for simple, non-dynamic Web sites?

Rather than putting resources into providing alternatives, web developers should work toward building dynamic, "rich" sites and web applications that are accessible. The supposition that it is difficult or impossible to provide dynamic services or content accessibly is incorrect. Accessibility must be considered in the very beginning design stage. When accessibility issues are considered in the personas used in design, creative designers can easily provide accessible web sites and applications.

Software that attempts to automatically generate a one-size-fits-all “text only” version of a site or other similar alternative cannot provide a user experience equal to that of a well-designed site used with adaptive technology (such as a screen-reader) selected and configured to meet the specific needs of its user. For example, if a site contains a quiz, the accessible alternative most likely will not provide interactivity, thus the student does not get feedback or knowledge and skills reinforcement. Furthermore, manually generated accessible alternatives frequently are forgotten or ignored and fall out of date. In cases where an alternative site is the only option, it must be maintained at all times. A model for this is Amazon's mobile site, which is preferred by many screen reader users due to its clear organization and elimination of extraneous information. Developments in the area of information delivery to mobile devices may provide paradigms to assist with accessible web development in general